Anti-Money Laundering Guidance on Customer Identification
Programs (CIPs)
On July 28th 2004,
the federal financial institution regulatory agencies issued Bank
Secrecy Act (B.S.A.) procedures for examining each domestic and foreign
banking organization's customer identification program (CIP), which
is required by section 326 of the USA PATRIOT Act (codified in the
B.S.A. at 31 U.S.C. 5318(l)). These procedures are contained in FIL-90-2004.
The USA PATRIOT
Act, signed into law on October 26, 2001, established new and enhanced
measures to prevent, detect, and prosecute money laundering and terrorism.
The regulation implementing section 326 of the Act requires each financial
institution to implement a written CIP that includes certain minimum
requirements and is appropriate for its size and type of business.
The CIP must be incorporated into the financial institution's anti-money
laundering compliance program, which is subject to approval by the
financial institution organization's board of directors. Compliance
with the regulation was required by October 1, 2003.
Kilclare has formatted
this guidance into a template for use in VA which could be used as
a starting point in any internal assessment of your organizations
compliance with the CIP requirements.
The procedures
in FIL-90-2004 augment existing procedures assessing Anti-Money Laundering
programs and Bank Secrecy Act compliance, and do not replace this
guidance. The existing BSA procedures have already been formatted
for use in VA and this template is included in the download table
with the FDIC Primary Modules.
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list contains the knowledgebase content available from documents in
the public domain issued by The Federal Deposit Insurance Corporation.
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